ML18052A615
| ML18052A615 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/25/1986 |
| From: | Kuemin J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8607290214 | |
| Download: ML18052A615 (4) | |
Text
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consumers Power POWERINli MICHlliAN'S PRDliRESS General Offices~ 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-0550 July 25, 1986
- Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
INADEQUATE CORE COOLING INSTRUMENTATION -
REACTOR VESSEL LEVEL MONITORING SYSTEM - PROPRIETARY INFORMATION Consumers Power Company letter of June 11, 1986 submitted Technology for Energy Corporation (TEC) Summary Report on the Palisades Plant Reactor Vessel Level Monitoring System and Program Tests.
The report, numbered R-86-005, is considered proprietary information by TEC and is so stated within the report.
However, not included with the submittal, as required by 10CFR2.790(b), was an affidavit attesting to the proprietary nature of the TEC report.
Attached hereto is an Affidavit executed by Mr R A Hendrick, President of Technology for Energy Corporation which provides the necessary information to support.the withholding of TEC Report R-86-005 from public disclosure.
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tKuemin Staff Licensing Engineer CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment r 0607290214 060725 r:*, i
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A F F I D A V I T STATE OF TENNESSEE
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CoUNTY OF KNOX
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I, R. A. Hedrick, being duly sworn, hereby say and depose:
- 1.
I am President of Technology for Energy Corporation, hereinafter known as TEC, and am authorized to execute this Affidavit *
. 2.
I am familiar with TEC' s Corporate Procedures for preparation and control of.design documentation.
- 3.
I am familiar with TEC Report R-86-005, "Summary Report*,
Reactor Vessel Level Monitoring System and Program Test Series for the Palisades Plant," referred to as "Document."
Information contained in this Document has been classified as proprietary in accordance with the procedures established bY TEC for the control and protection of information.
~. The Document contains information of a proprietary and confidential nature which is not available in public sources. Based on my experience, I am aware that other companies regard information of the kind contained in the Document as proprietary and confidential.
- 5. The information contained in the Document is considered by TEC to be proprietary because it reveals certain distinguishing aspects.
of the TEC Inadequate Core Cooling System, hereinafter referred to as ICC System, which secure competitive advantage to TEC for reactor vessel coolant level measurement.
The Document also includes information which affords TEC an opportunity to obtain a competitive advantage over those who do not or may not know or use the information contained in the Document.
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- 6.
The Document provides information which reveals the TEC ICC.
System developed over the past several years~ TEC has invested over one mHlion dollars and many man years of effort in developing this system.
- 1.
The Document contains information which is vital as a qompetitive advantage to TEC and would be helpful to competitors of TEC.
The'disclosure of the proprietary informatipn contained in the Document to a competitor would permit the competitor to reduce its expenditure of money and manpower and to improve its competitive.position by giving it extremely valuable insfghts i~to the TEC ICC System. It would also result,in substantial harm to the competitive position of T~C.
- 8. Based on my experience, I do not believe that the background, data, and incentives of TEC's competitors are sufficiently similar to the corresponding background, data, and incentives of TEC to reasonably expect such competi~ors to be in a position to duplicate TEC's proprietary information contained.in the Document without similar investments.
- 9.
In accordance with TEC's*policies governing the protection arid control of information, proprietary information contained in the
- Document has been made available, on. a limited basis*, to others outside TEC only as required and under suitable agreement providing for non-disclosure and limited use of the information.
- 10.
The Document has been made available to the U.S. Nuclear Regulatory Commission in confidence, with the stipulation t~at the information contained in the Document not be duplicated or disclosed, in whole or in part, without the express writte~ consent of Technology for Energy Corporation.
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3 THAT the statements made hereinabove are, to the best.of my knowledge, information and belief, truthful and complete.
SWORN TO AND SUBSCRIBED before me this d :?.~day of
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My Commission Expires: